Summary:
Summary Statement of Deficiencies D5209 PERSONNEL COMPETENCY ASSESSMENT POLICIES CFR(s): 493.1235 As specified in the personnel requirements in subpart M, the laboratory must establish and follow written policies and procedures to assess employee and, if applicable, consultant competency. This STANDARD is not met as evidenced by: Based on a review of the laboratory's policies, personnel competency records, and staff interview, the laboratory failed to follow their policy to document all required components of competency when 3 of 3 testing personnel were assessed for the prothrombin time (PT) test and the automated semen analysis test in 2017. Findings include: a. The laboratory's policy for personnel competency states, "The procedures for evaluation of the competency of the staff must include, but are not limited to: direct observation of routine patient test performance, monitoring the recording and reporting of test results, review of intermediate test results or worksheets, quality control records, proficiency testing results, and preventive maintenance records, direct observation of performance of instrument maintenance and function checks, assessment of test performance through testing internal and/or external proficiency testing samples, and assessment of problem solving skills." b. Records showed the competency assessments in 2017 of 3 of 3 testing personnel who perform prothrombin time testing on the Abbott i-STAT involved a written quiz, reading the test procedure, and an attestation, signed by the testing personnel and the technical consultant, stating, "I am able to demonstrate and understand 1) patient specimen collection, handling and identification, 2) testing procedure, 3) quality control, 4) reagent test pack and control handing and storage requirements, 5) documentation and result reporting procedures, and 5) (sic) trouble shooting error messages for the i-STAT system. c. Records showed the competency assessments in 2017 of 3 of 3 testing personnel who perform automated semen analysis using the SQA-V Gold Semen Analyzer involved a written quiz, reading the test procedure, viewing SQA-V videos, Statement of Deficiencies (X1) Provider/Supplier/CLIA Identification Number (X3) Date Survey Completed Name of Provider or Supplier Street Address, City, State -- 1 of 4 -- and an attestation, signed by the testing personnel and the technical consultant, stating, "I have read the SQA-V Analyzer procedure and viewed the MES-Global videos. I can perform daily and weekly maintenance procedures. I understand the importance of a properly filled capillary in order to obtain accurate results. I understand all reagent storage requirements and proper handling and use. I have performed Quality Control testing and understand how to troubleshoot and document failed QC testing. I can accurately perform patient testing along with documentation of results into the patient's EMR." d. Staff confirmed the evaluations did not contain all the components of competency assessment as required by federal CLIA regulation. D5421 ESTABLISHMENT AND VERIFICATION OF PERFORMANCE CFR(s): 493.1253(b)(1) Each laboratory that introduces an unmodified, FDA-cleared or approved test system must do the following before reporting patient test results: (1)(i) Demonstrate that it can obtain performance specifications comparable to those established by the manufacturer for the following performance characteristics: (1)(i)(A) Accuracy. (1)(i) (B) Precision. (1)(i)(C) Reportable range of test results for the test system. (1)(ii) Verify that the manufacturer's reference intervals (normal values) are appropriate for the laboratory's patient population. This STANDARD is not met as evidenced by: Based on a review of the laboratory's policies, the lack of verification records, and staff interview, the laboratory failed in 2018 to verify before initial patient use on January 26, 2018, the manufacturer's stated performance specifications of the prothrombin time (PT) test using a replacement Abbott i-STAT portable clinical analyzer (serial #312253). Findings include: a. On 1-26-18, the laboratory began using a replacement i-STAT analyzer for PT testing of patient specimens. b. The laboratory's policy states, "Method performance will be verified (validated) by testing 1) accuracy, 2) precision, 3) reportable range of test results for the test system, and 4) verify that the manufacturer's reference intervals (normal values) are appropriate for the laboratory's patient population. Documentation will be maintained for 2 years after test instrument and/or method is discontinued. TUCC will ensure that the test systems, equipment, instruments, reagents, materials and supplies function according to manufacturer's specification." c. No documentation existed that the laboratory verified that they could obtain on the replacement i-STAT analyzer, the analytical claims of the manufacturer. d. Staff stated they were unaware of this regulatory requirement for replacement analyzers and confirmed that the manufacturer's performance specifications had not been verified using this replacement test system before reporting patient results. D5781